OSHA Injury Categories and Recordkeeping Requirements

OSHA recordkeeping requirements under 29 CFR Part 1904 obligate most employers to log work-related injuries and illnesses on internal forms, post an annual summary for employees to see, and report the most serious events — fatalities, in-patient hospitalizations, amputations, and losses of an eye — directly to the agency within hours. Whether a specific case has to be logged depends on how the injury happened, how it was treated, and what happened to the employee afterward. Get the classification wrong and the fines can reach six figures per violation.

Which Employers Have to Keep Logs

If your company had ten or fewer employees at all times during the previous calendar year, you are generally exempt from maintaining OSHA injury and illness logs. The headcount applies to the whole company, not each location. Cross ten at any point in a year and you lose the exemption for the following year.¹

Certain low-hazard industries are also partially exempt regardless of size. OSHA publishes a list by NAICS code covering sectors like retail, finance, and real estate where injury rates fall below a set threshold. Establishments on that list do not maintain routine logs.²

One rule applies to every employer covered by the OSH Act, regardless of size or industry: fatalities, in-patient hospitalizations, amputations, and losses of an eye must be reported directly to OSHA. No exemption reaches that obligation.¹

When an Injury Is Work-Related

An injury or illness is work-related if an event or exposure in the work environment caused, contributed to, or significantly aggravated the condition. Work-relatedness is presumed for anything that happens in the work environment unless a specific exception applies.³

The exceptions are narrower than many employers assume. A case is not work-related if it falls entirely within one of these situations:

The employee was at the worksite as a member of the general public, not as an employee.
Symptoms surfaced at work but resulted entirely from a non-work event or exposure.
The injury came from voluntary participation in a wellness program, blood donation, flu shot, exercise class, or recreational activity.
The employee was eating or preparing food for personal consumption. Food contaminated by workplace chemicals, or food supplied by the employer that causes illness, still counts.
The employee was doing personal tasks during non-assigned hours.
The injury resulted from personal grooming, self-medication for a non-work condition, or was intentionally self-inflicted.
A motor vehicle accident occurred on a company parking lot or access road while the employee was commuting.
The condition is a common cold or flu. Contagious diseases like tuberculosis or hepatitis A contracted at work are recordable.
The condition is a mental illness, unless the employee voluntarily provides a physician’s opinion tying it to work.

These exceptions apply only where the listed cause is the sole reason for the injury. If workplace factors also contributed, the case is work-related.³

What Makes a Case Recordable

A work-related case has to land on the OSHA 300 Log if it meets any one of six triggers:⁴

Death.
Days away from work. Count calendar days after the day of injury; you may cap the count at 180.
Restricted work or job transfer. The case is recordable if the employee cannot perform routine job functions (activities done at least once a week) or cannot work a full shift, or if a healthcare professional recommends either restriction. Slowing production without missing any routine tasks does not count.
Medical treatment beyond first aid.
Loss of consciousness, regardless of duration.
A significant injury or illness diagnosed by a physician or licensed healthcare professional, such as a fracture, punctured eardrum, or ruptured organ, even when none of the other triggers apply.

First Aid Versus Medical Treatment

The line between a recordable case and a non-recordable one often turns on the type of treatment given. OSHA maintains a closed list of what qualifies as first aid. Anything on the list is first aid; anything else is medical treatment and makes the case recordable.⁴

First aid includes non-prescription medications at non-prescription strength, tetanus shots (but not hepatitis B or rabies vaccines), wound cleaning and flushing, bandages and butterfly closures like Steri-Strips (but not sutures or staples), hot or cold therapy, non-rigid supports like elastic wraps (but not rigid immobilization), temporary splints or neck collars used only during transport, draining a blister or drilling a fingernail, eye patches, removing foreign objects from the eye by irrigation or cotton swab, removing splinters with tweezers, finger guards, massage (but not physical therapy or chiropractic care), and fluids for heat stress relief.

The list is exhaustive. Stitches push a case into recordable territory; butterfly bandages do not. A doctor prescribing ibuprofen at prescription strength counts as medical treatment even though the drug is sold over the counter.

Severe Injuries You Must Report Directly to OSHA

Four categories of events require a direct notification to OSHA on top of any logging. The reporting clock starts when you or anyone acting on your behalf learns of the incident.⁵

A work-related fatality must be reported within 8 hours. If you do not immediately recognize the connection to work, the window starts when you do.
An in-patient hospitalization of one or more employees must be reported within 24 hours. In-patient means a formal admission for care, not an emergency room visit and release.
An amputation must be reported within 24 hours. This covers complete or partial loss of a limb or external body part, including fingertip amputations with or without bone loss and medical amputations from irreparable damage.
A loss of an eye must be reported within 24 hours.

You have three ways to make the report: call the nearest OSHA area office, call the 24-hour hotline at 1-800-321-6742, or submit through OSHA’s online form. If the local office is closed, voicemail, fax, and email do not qualify. Use the hotline or the online form.⁶

The Three Forms and How Long to Keep Them

Recordkeeping runs on three forms:

Form 300, the running log where each recordable case gets a line entry describing what happened and the severity.
Form 301, the incident report completed for each individual case with details about the employee and the circumstances.
Form 300A, the year-end summary that totals the log across categories. This is the form posted publicly in the workplace.

All three forms must be kept for five years after the end of the calendar year they cover. During that retention period, the Form 300 Log must be updated if you discover new recordable cases or need to reclassify an earlier entry. The 300A and Form 301 reports do not have to be updated, though you may update them voluntarily.⁷

The 300A must be posted where employee notices normally appear from February 1 through April 30 each year. A company executive has to certify the summary before it goes up.

Electronic Submission Through the ITA

Some employers must also submit data through OSHA’s Injury Tracking Application. Establishments with 250 or more employees submit data from Forms 300, 300A, and 301. Establishments with 20 to 249 employees in designated industries submit data from Form 300A only. The deadline is March 2 of the year following the calendar year covered. Submissions received after March 2 through December 31 are technically late.⁸

Privacy Concern Cases

Some cases involve information OSHA does not want posted on a log employees can read. For a privacy concern case, the employer enters “privacy case” on the 300 Log instead of the employee’s name and maintains a separate confidential list linking case numbers to identities. Coworkers and their representatives have no right to see the confidential list.

Privacy concern cases include injuries or illnesses involving an intimate body part or the reproductive system, injuries from sexual assault, mental illnesses, HIV, hepatitis, or tuberculosis, needlestick injuries and cuts from sharps contaminated with another person’s blood or infectious material, and any other illness where the employee voluntarily asks that their name be withheld.

State Plans May Add Requirements

About half of states run their own OSHA-approved programs. State plans must use recording criteria that are substantially identical to the federal rules, so what counts as recordable should not change across state lines. State plans may impose stricter or supplemental requirements in other areas — industry exemptions, severe injury reporting deadlines, retention periods, employee access — with federal approval. Check the specific rules where your establishment operates.⁹

Penalties for Getting It Wrong

OSHA adjusts penalties annually for inflation. Maximum fines effective January 15, 2025 and carried into 2026 are:¹⁰

Up to $16,550 per serious or other-than-serious violation.
Up to $165,514 per willful or repeated violation.
Up to $16,550 per day past an abatement deadline.

Each unrecorded case on the 300 Log can be treated as a separate violation, so poor recordkeeping stacks quickly. Failing to report a fatality, hospitalization, amputation, or eye loss within the required window is its own violation, and OSHA may treat it as willful if the employer knew about the obligation and ignored it. When in doubt about whether a case is recordable, record it. An entry can be lined through later if it turns out to be non-recordable, but a missed record cannot be undone once OSHA finds it.

1
Occupational Safety and Health Administration. 1904.1 – Partial Exemption for Employers With 10 or Fewer Employees
2
Occupational Safety and Health Administration. Non-Mandatory Appendix A to Subpart B – Partially Exempt Industries
3
Occupational Safety and Health Administration. 1904.5 – Determination of Work-Relatedness
4
Occupational Safety and Health Administration. 1904.7 – General Recording Criteria
5
Occupational Safety and Health Administration. 1904.39 – Reporting Fatalities, Hospitalizations, Amputations, and Losses of an Eye as a Result of Work-Related Incidents to OSHA
6
Occupational Safety and Health Administration. Report a Fatality or Severe Injury
7
Occupational Safety and Health Administration. 1904.33 – Retention and Updating
8
Occupational Safety and Health Administration. Injury Tracking Application (ITA) Information
9
Occupational Safety and Health Administration. 1904.37 – State Recordkeeping Regulations
10
Occupational Safety and Health Administration. OSHA Penalties